8th Annual IBA Finance & Capital Markets Tax Conference
28 Jan - 29 Jan 2019
Session information
Committee(s)
Taxes Committee
(Lead)
Description
• BEPS / financial transactions transfer pricing in light of new OECD Draft Transfer Pricing Guidelines (e.g. Italy has aligned TP practice with BEPS and 2017 OECD Transfer Pricing) • EU dispute resolution • Penal aspects to inappropriate transfer pricing • Update on transfer pricing on group internal guarantees • Transfer pricing on group loans including cash pooling loans • Treatment of group loans under functional currency • Hidden equity (re-characterized group loans) and appropriate interest payments • EU country by country reporting • Permanent establishments
Session / Workshop Chair(s)
| Pascal Hinny | Lenz & Staehelin, Zürich, Switzerland |
Speakers
| Annabelle Bailleul-Mirabaud | CMS Francis Lefebvre , Neuilly-sur-Seine, France; Membership Officer - Europe, Taxes Committee |
| Murray Clayson | |
| Ryan Kelly | Alston & Bird, Washington, District of Columbia, USA |
| Raul-Angelo Papotti | Chiomenti Studio Legale, Milan, Italy; Website Officer, Taxes Committee |